Environmental Engineering Reference
In-Depth Information
erent set of questions, because it applies to industrial chemicals,
metals and minerals. Small village enterprises do not produce ethylene or aluminum;
exports subject to REACH come almost exclusively from large, capital-intensive industries.
Chemicals remain a high-technology sector, concentrated in developed countries; more
than half of all EU imports that are subject to REACH come from the USA, Switzerland,
Russia, Norway and Japan (Ackerman et al., 2006). Mining, of course, is located wherever
the relevant ores can be found; the same companies that operate mines in the USA and
Australia are often involved in Chile and southern Africa as well.
If REACH a
REACH raises a di
ff
ects will be felt by chemical industries
in developed countries, and by mining companies operating around the world. And wher-
ever the e
ff
ects trade, therefore, its primary e
ff
ects of REACH are felt, they must have some relationship to the costs of com-
pliance with the new rules. Seen in the proper perspective, those compliance costs turn out
to be remarkably small.
ff
Costs of REACH: billions of euros small
After an intense
fi
ve years of debate, from the initial proposal in 2001 to the
fi
nal adop-
tion in 2006, REACH went into e
rst 11 years of REACH, from
2007 through 2018, all the 30 000 or so chemicals that are sold in the EU in quantities
above 1 tonne per year will have to be registered and tested. Those that are found to pose
health or environmental hazards, presumably a small minority of the tested chemicals,
will be subject to additional regulations.
As regulations go, this is a big one, a
ff
ect in 2007. During the
fi
ecting every aspect of an enormous industry.
Complaints about the cost of regulation are commonplace, and commonly exaggerated
(Ackerman, 2006) - but could REACH be the exception, the regulation that actually is
expensive enough to interfere with economic prosperity? Such fears were ampli
ff
ed by two
early studies of the costs of REACH, sponsored by German and French industry associ-
ations. (Perhaps living up to national stereotypes, the German study was a ponderous,
methodical, 200-page report, while the French study was released only in the form of col-
orful PowerPoint slides presenting its conclusions.) In the opinion of these industry
groups, the German and French economies would be devastated by the adoption of
REACH.
Numerous other studies of the costs of REACH were conducted - and no one else
found the costs to be large enough to cause noticeable damage to European economies.
The European Commission estimated the costs at
fi
2.3 billion; a study I directed, for the
€
Nordic Council of Ministers, used di
ff
erent technical assumptions and came up with an
estimate of
3.5 billion. Other estimates were in the same range, usually between
2
€
€
billion and
4 billion (Witmond et al., 2004). (Our study, Ackerman and Massey, 2004
includes a technical appendix detailing the numerous methodological errors of the
German industry study, which account for its much higher result.)
How small are a few billion euros? Most people have no real understanding of quanti-
ties in the billions; such
€
gures are so large that they have to be compared to something
in order to be usefully comprehended. If the default standard of comparison is your own
fi
fi
t organization, then a few billion euros
looks enormous; if they were piled on a table, they would make a very big pile of money.
But the costs of REACH - the costs of registering and testing 30 000 chemicals - are
not piled on a table anywhere; rather, they are spread across the breadth of the European
nances, or even a small business or non-pro
fi
